Financial institutions and other section 6 entities (e.g., banks and similar entities listed in the Act)
- Ongoing duty to determine whether you possess or control property of a listed foreign national or their family member (Clause 3; s.6).
- Must disclose without delay to RCMP or CSIS if you have reason to believe you hold such property (Clause 4; s.7(2)(a)).
- May be ordered by Cabinet to provide information needed to establish whether you hold relevant property (Clause 1(c)).
- Must implement any freeze or prohibition orders issued under section 4 (Clause 1).
Businesses and nonprofits
- Every person in Canada and every Canadian outside Canada has a duty to disclose if they have reason to believe they hold property of a listed foreign national or their family member (Clause 4; s.7(2)(a)).
- You may need to adjust compliance processes to identify and report potential holdings connected to listed persons and their family members (Clauses 3 and 4).
Parliament and transparency
- A motion signed by at least 50 MPs or 20 Senators can trigger a debate to amend or revoke an order or regulation made under section 4 (Clause 2).
- Each House must take up a motion within 6 sitting days and debate for up to 3 hours; if both Houses adopt and concur, the change takes effect on the day specified, not earlier than the concurrence vote (Clause 2).
- The Minister must publish an annual report by December 10 describing orders, permits and reasons, enforcement efforts and resources, and international coordination, including meetings with foreign governments (Clause 5).